Subrecipient agreements

Subaward was included in the funded proposal

The department begins the process by submitting a Subaward Request for each subrecipient included in the funded proposal. Check again to ensure your Subrecipient’s relationship to UMB is truly that of a Subrecipient, and not that of a supplier/vendor. Review the vendor or subrecipient guidance.

This page outlines the Sponsored Programs Administration (SPA) process. SPA issues subawards. The Center for Clinical Trials and Corporate Contracts (CCT) issues subawards under industry-sponsored clinical trials. Strategic Sourcing and Acquisition Services issues consultant and vendor agreements

Initiate the Subaward Request after UMB receives the award notice and the Award has been set up in Kuali Research. You will need the Kuali Research (KR) Award ID and other information to complete the Subaward Request.

After-the-fact Subawards

Your subrecipient must be listed as an Approved Subaward in the KR Award record so that you can submit a Subaward Request.

If the proposed subaward was not part of the original proposal submitted to the sponsor, sponsor approval is usually required before UMB issues the subaward.

• Is the funding award a grant or a contract?  Most agreements and contracts require that UMB obtain the sponsor's prior approval before entering into any subaward. Review the agreement terms and conditions.
• Who is the sponsor?  For NIH grants (only), sponsor approval is required for foreign subrecipients but not for domestic (U.S.) subrecipients.  For all other sponsors, you must review the award terms and conditions and sponsor policies to determine whether sponsor approval is required.

If NO prior approval is needed, send an email to SPA-Subcompliance@umaryland.edu with the request to update the KR Award record with the Approved Subaward. Provide the KR Award number and the organization(s) that should be added.

If prior approval is needed, work with your SPA Team to request sponsor prior approval. The request is initiated by the PI and signed by SPA. A written response from the sponsor grant/contract officer is required. Once that prior approval documentation is obtained, SPA will update the KR Award ID with the Approved Subaward.

Helpful templates and information

Budget. Use the Budget template-subaward request. A budget is required for new subawards and for modifications that add dollars to the subaward. The budget will include salary, fringe benefits (at the subrecipient's rate), operating expenses (supplies, equipment, travel), and F&A costs.

For fixed price/deliverable subawards, provide a payment schedule including deliverables (and due dates) and payment dates and amounts.

Scope of Work. This document should describe, with a reasonable amount of detail, what the subrecipient investigators will do for the project. Statement of Work template

Special conditions or requirements to be included in the subaward may be described in the Subaward Request. Examples: additional reports, data, shared research materials, and timetables. Include these in the Comments section of the form.

Commitment form: For new subawards, the Subrecipient Commitment Form must be‌ completed and signed by the subrecipient’s authorized official‌ and uploaded to the Subaward Request.

Unique Entity ID (UEI) requirement:  When the prime sponsor is federal, the subrecipient's Unique Entity ID (UEI) is required by award terms and is used for UMB's reporting to the federal government. Subrecipients obtain a UEI from Sam.gov.

When applicable, SPA will require:

• IRB or IACUC approvals.
• Human subject training certifications for all key personnel.
• Approval for use of select agents.
• Financial Conflict of Interest (FCOI) certifications for all key personnel (NIH-funded projects).
• Copy of subrecipient's Federally Negotiated Indirect Cost Rate Agreement, when applicable and if not provided in the proposal

The PI authorizes the subaward request, via workflow for the Subaward Request or via email for internally funded subawards.

New subawards undergo a risk assessment process, which may involve communications between SPA and the subrecipient. If the proposed subrecipient is a foreign organization, an export compliance review is performed.  Under certain circumstances, the Conflict of Interest office is notified.

The initiator/submitter of the Subaward Request can monitor the status of the workflow approvals:

Log into Kuali Build. Click on My Documents, and then select Submitted

If the Status column says "Complete", then the form has been approved. Submitters receive an email with a copy of the approved form. At this point, the Kuali Research record for this subaward has been created and the SPA Sub Team will send the subaward to the subrecipient.

If the Status column says "In Progress", then the form is still in the workflow. Click on the link in the Form column to view the form, then in the left column of the form, toggle from Review to Status. If the form is at the approval stop for "SPA Approval - Sub Team", look at the date of notification under "Submitter notified that SPA Sub Team is receiving form". This starts the 15-business-day turnaround time in SPA's business process for subaward review. After 15 business days, if you have not heard from the SPA Sub Team, send an email (including your KB form number) to SPA-Subteam@umaryland.edu

The subaward is sent to the subrecipient for signature and the department is notified.

The subaward is signed in SPA only when all approvals are in place.

The fully executed subaward is sent to the subrecipient and the department.

The department requests a purchase order via Quantum standard procedures.

The department informs the subrecipient and SPA of the purchase order number.

• SPA informs the subrecipient of the purchase order number
• The subrecipient submits an invoice, referencing the assigned purchase order number
• Invoices are processed by Accounts Payable
• Review each invoice to confirm that the subrecipient has performed the work and that the charges are reasonable, allowable, and within budget. Subrecipient Monitoring Invoice Checklist
• PI must review and approve in writing all expenditures for work completed during the period stated on any invoice received.
  As an example, the PI could confirm via email to the department administrator that the subrecipient has made progress in the project work, completed milestones (describe), or submitted data and/or reports and that the expenditures are approved as invoiced.

Tips

Monitor your subrecipient to ensure that they are invoicing regularly and timely.

Monitor your subrecipient to ensure that progress is being made. Document the progress and completion of project work: keep records of telephone calls, meetings, emails, reports, deliverables, and compliance requirements (such as IRB approvals).

As part of the invoice review, compare the effort reported by key persons with the approved (awarded) effort to ensure that the effort commitment is met. The effort should be reasonable for the progress made. If there is a "disconnect", follow up with your subrecipient contacts to work through the issue.

If the subrecipient is not performing or has not submitted the required reports, notify Accounts Payable to delay future payments until the issue is resolved. Document the issue and related communications. Keep the SPA Subawards Team appraised of the issue and resolution.

The department requests changes to the subaward using the Subaward Request. Possible changes include:

• Add continuation year funding (increase and extend)
• Increase or reduce the subrecipient’s budget
• Change of Subrecipient PI
• Carryover of funds from one project year to the next
• Early termination of the subaward
• Change of subrecipient (e.g., due to transfer of subrecipient PI)
• Extension of agreement (The term of the subaward cannot be extended beyond that of UMB's award.)

Approved changes will be incorporated in a modification to the subaward issued by SPA.

Some changes require sponsor approval. When required, sponsor approval must be obtained before the subaward can be modified. Requests for sponsor approval are initiated by the PI and signed off by the SPA authorized official.

Requests from the subrecipient regarding changes to the agreement will be forwarded to the UMB PI for review and approval.

In the Subaward Request

• Identify the change(s) to be made - see instructions
• Include updated approvals (human subjects, animals) and certifications when applicable
• Upload a budget for any increase to the subrecipient's current awarded budget
• When applicable, provide an updated scope of work and/or reporting requirements

The Subaward Request will be verified and authorized by the PI.

Changes to the purchase order:

The department must process approved changes to the purchase order when required.

A subaward should be closed out at the end of the project after all technical reports or other deliverables have been completed by the subrecipient, and after the subrecipient's final invoice has been paid. The steps to close out a subaward should also be taken if a subaward is terminated early, before the end date in a signed agreement.

Subaward Request - Early Termination

For closeout, the following items are needed:

• Within 30-45 days after the end of the budget period, the subrecipient must submit an invoice marked as "Final". The PI should approve this final invoice for payment only if all the required reports and deliverables have been received from the subrecipient.
• The department administrator should ensure that payment of the final invoice expense has been posted. Contact Strategic Sourcing and Acquisition Services to have any remaining balance of the subrecipient purchase order disencumbered.
• The final invention report to the sponsor must include any inventions first conceived or first reduced to practice by the subrecipient personnel under the subaward.
• If UMB and the subrecipient entered into any material transfer agreement (MTA) related to the subaward, review the MTA to determine if the exchange of materials is still needed or should be ended. Contact the Center for Clinical Trials and Corporate Contracts for assistance.
• SPA will request any other documents that may be required from the department or the subrecipient for closeout.